Legal Opinion

Bell v. Commissioner

United States Tax Court

Decided June 30, 1959No. Docket No. 64041Published

In 1952 and 1953, petitioner was an employee of the Government of American Samoa and in each of those years received, in addition to regular compensation, cost-of-living allowances which were calculated on 25 per cent of his regular pay.

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In 1952 and 1953, petitioner was an employee of the Government of American Samoa and in each of those years received, in addition to regular compensation, cost-of-living allowances which were calculated on 25 per cent of his regular pay. Petitioner excluded these cost-of-living allowances from his gross income and claims they are excludible under section 116(j), I.R.C. 1939. Held, that in order for such cost-of-living allowances to be excludible from a taxpayer's gross income they must have been paid "in accordance with regulations approved by the President." Held, further, that during the…

1Opinion of the Court

George R. Bell, Petitioner, v. Commissioner of Internal Revenue, Respondent

Bell v. Commissioner

Docket No. 64041

United States Tax Court

32 T.C. 839; 1959 U.S. Tax Ct. LEXIS 133;

June 30, 1959, Filed

Decision will be entered for the respondent.

In 1952 and 1953, petitioner was an employee of the Government of American Samoa and in each of those years received, in addition to regular compensation, cost-of-living allowances which were calculated on 25 per cent of his regular pay. Petitioner excluded these cost-of-living allowances from his gross income and claims they are excludible under section…

2Cases cited5 opinions

  1. Brunelle v. CommissionerUnited States Tax Court · 1950
  2. Davis v. CommissionerUnited States Tax Court · 1958
  3. Bell v. CommissionerUnited States Tax Court · 1958
  4. Barnett v. United StatesDistrict Court, D. Hawaii · 1959
  5. Bell v. CommissionerUnited States Tax Court · 1959

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